On September 5, 2025, the Staff of the Division of Trading and Markets of the U.S. Securities and Exchange Commission (“SEC”) granted no-action relief that allows members of the Financial Industry Regulatory Authority, Inc....more
BUSY FOURTH QUARTER FOR SEC STAFF - During the fourth quarter of 2021, the Securities and Exchange Commission reopened the comment period for its controversial compensation clawback rule that it initially proposed in 2015...more
Quick Hitters - On December 15, 2021, the SEC (i) proposed amendments to address “potentially abusive practices” by corporate insiders related to 10b5-1 trading arrangements, grants of options and other similar equity...more
In October 2019, for the third consecutive year, the Staff of the Division of Corporation Finance (Staff) of the U.S. Securities and Exchange Commission (SEC) issued guidance concerning companies’ ability to exclude...more
The SEC’s Division of Corporation Finance recently announced changes to its process for responding to no-action requests that seek exclusion from proxy materials of shareholder proposals submitted under Exchange Act Rule...more
On September 6, 2019, the Division of Corporation Finance (Division) of the US Securities and Exchange Commission (SEC) announced1 a significant change to its process with respect to reviewing no-action requests submitted to...more
The SEC has denied no-action relief to exclude the following shareholder proposal submitted to several companies by Jonathan Kalodimos: Resolved: Shareholders of ITT Corporation ask the board of directors to adopt and...more